EFTA01250905.pdf

From: " To: ' " Cc: " Subject: RE: Notification -- Appointment of Counsel Date: Tue, 27 Apr 2021 02:03:09 +0000 Importance: Normal Actually, mind holding off please? The agent and I still need to add our signatures, and I need to add the first page. From: Sent: Monday, April 26, 20218:24 PM To: Cc: Subject: FW: Notification — Appointment of Counsel Can you please add this to next NTW production? Thanks, From: Megan Benett Sent: Wednesday, April 14, 2021 5:43 PM To: Cc: >; Lisa Ranieri ; Lisa Ranieri Subject: RE: Notification -- Appointment of Counsel Apologies for the delay — signature pages are attached. Anthony and I were both remote in locations without printers for some time but here you go. Thanks. Megan From: Sent: Thursday, April 8, 2021 1:45 AM To: Megan Benett < Cc Lisa Ranieri • Subject: RE: Notification -- Appointment of Counsel Hi Megan, Would you be able to please send us a copy of the executed proffer agreement with your and your client's signatures? We're going through our records and noticed we're missing that document. Thanks, EFTA01250905 From: Sent: Wednesday, January 27, 2021 1:26 PM To: Megan Benett Cc: ; Lisa Ranieri O; Subject: RE: Notification -- Appointment of Counsel Hi Megan, Attached please find a copy of the proffer agreement and VTC addendum for today's interview with Thanks, From: Sent: Tuesday, January 26, 2021 1:24 PM To: Megan Benett Cc: ; Lisa Ranieri O; Subject: RE: Notification -- Appointment of Counsel I'm happy to have you try to forward the invitation to MI yourself. If that doesn't work, then I can send a separate invitation directly to M. Best, From: Megan Benett Sent: Tuesday, January 26, 2021 9:31 AM To: Cc: a; Lisa Ranieri Subject: Re: Notification -- Appointment of Counsel Thanks, Maureen. Can I forward the details of the call in the invite to M? If it has to come directly from you, let me know and I'll get you his email later today. Talk tomorrow. Megan Sent from my iPhone On Jan 25, 2021, at 12:21PM, wrote: Hi Megan, How about we plan for 5:30pm on Wednesday 1/27? I'll send out a calendar invitation with the WebEx VTC details. Would you please let me know to what email address I should send invitation? As I believe mentioned to you when you previously spoke on the phone, we can confirm that is not a target of the investigation. We are seeking to interview because we believe we may wish to call to testify as a potentially trial witness. If you would like to have a discussion about what category falls into under the USAM, I'd be happy to have a call to talk about our thinking on that matter. EFTA01250906 You are correct that we are open to taking steps that would allow to testify without needing to invoke his privilege against self-incrimination. In that vein, we are open to the possibility of something like a non-prosecution agreement or immunity. As you noted, though, we cannot promise any such resolution at this time, and any such resolution would have to be approved by our supervisors after has been fully debriefed. To help. feel comfortable speaking with us, we are happy to proceed under our office's standard proffer agreement. Please feel free to call my cell at 347-344-8771 if you would like to discuss or have any other questions. Best, Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10. From: Megan Benett < Sent: Friday, January 22, 2021 7:00 PM To: Cc: Lisa Ranieri Subject: RE: Notification -- Appointment of Counsel Hi all— = is working until 5 pm ET every day next week. Could we do it on an evening next week? I'm available for an interview at 5:30 pm ET or later any day next week. Also, could you confirm that is not a target of the investigation and let me know whether you think he falls within the definition of a subject? Last, I believe we discussed the possibility of pursuing a non-pros if your team found credible and helpful — that is important for to know before committing to the interview, so please let me know your office's position on working toward that (though I know you cannot commit to entering into the agreement, can you tell me whether you are open to pursuing it following an interview(s)?) Thanks Megan From: Sent: Friday, January 22, 2021 9:05 AM To: Megan Benett < Cc: Lisa Ranieri Subject: RE: Notification -- Appointment of Counsel Hi Megan, No worries at all, and thanks for reaching out to M. The number I have is: Thanks, EFTA01250907 From: Megan Benett Sent: Friday, January 22, 2021 11:25 AM To: ; Megan Benett Cc: Lisa Ranieri Subject: RE: Notification -- Appointment of Counsel Hi all — ologies for not following up. I will get you a few dates / times in the next week or so asap — but have to confess that ilti phone number is sitting on a pad in my office and I'm actually out of state. I know your agents have his contact info. If you (or they) could forward his number to me today I'll try to get back to you later this afternoon. Thanks and happy new year Megan From: Sent: Thursday, January 21, 202110:06 AM To: Megan Benett Cc: Lisa Ranieri Subject: RE: Notification -- Appointment of Counsel Hi Megan, I'm following up on this in case this got lost in the mix — could you please let us know what dates and times might work for you and your client for an interview by videoconference? Thanks very much, and hope you're doing well-- From: Sent: Tuesday, December 15, 2020 3:57 PM To: Megan Benett .4t > Cc: Lisa Ranieri Subject: RE: Notification -- Appointment of Counsel Hi Megan, Thanks for following up. When we last spoke, we discussed a potential interview in mid-January, and you were going to confirm with your client before we firmed up dates. If that timing works for you, could you please let us know what dates are convenient for you and your client for an interview by video conference? Thanks very much, From: Megan Benett Sent: Tuesday, December 15, 2020 3:34 PM To: EFTA01250908 Cc: Lisa Ranieri Subject: RE: Notification -- Appointment of Counsel Hi Did we set a date for the call with MI and the agents etc.? I don't have it in my calendar and want to make sure the day / time are blocked. Please reply all so that my assistant Lisa (cc'ed here) knows the plans, as well. Thanks Megan From: Sent: Friday, December 4, 2020 1:58 PM To: Megan Benett < Subject: RE: Notification -- Appointment of Counsel That works well—thanks, and talk you then. From: Megan Benett Sent: Friday, December 4, 2020 1:21 PM To: Subject: RE: Notification -- Appointment of Counsel Yes — we got it done 'List under the wire late on Wed. Can we talk on Monday? I should be in my office all morning and early afternoon Thanks. Megan From: Sent: Friday, December 04, 2020 11:26 AM To: Megan Benett < Subject: Re: Notification -- Appointment of Counsel Hi Megan, Did the appointment of counsel go forward? Thanks, Sent from my iPhone On Dec 2, 2020, at 9:54 AM, Megan Benett wrote: Do you have contact info for the witness so I can at least get the financial affidavit completed? Let me know and thanks. Megan From: Sent: Tuesday, December 01, 2020 2:58 PM To: Cc: Megan Benett > )• Subject: Notification -- Appointment of Counsel FORM FOR NOTIFICATION OF **NEW** PRESENTMENTS TO THE ARRAIGNMENTS UNIT EFTA01250909  212-805-4051) Instructions: Use this form for all notifications to Mag Court of New Presentments (new arrests, extraditions, or surrenders). If applicable: • Attach Complaint/Indictment/VOSR specs to this email • Attach Conflict of Interest Form DO NOT use this form to schedule other events in Mag Court. For Arraignments for Previously Presented Defendants, Pleas, Detention Hearings, Substitution of Counsel Hearings, Deferred Prosecution Hearings, and Curcio Hearings, send an email to [email protected] AUSA NAME: PHONE NO: CELL: Type of Case: [1 New Arrest [ ] Voluntary Surrender [ ] Safe Keep [ VOSR [Choose one] [X] Appointment of Counsel (witness)] Docket No.: N/A If Indicted: USDJ: Referred to Mag Court for Arraignment: Charge(s)/ VOSR Specs: ** attach complaint/ indictment / VOSR specs to this email ** WITNESS D Counsel D Counsel Name Contact Info [FD/CJA/Retained?] 1 2 3 4 5 If Applicable, List of Conflicted D Counsel: Federal Defenders [e.g., same or related case; CW's counsel] ** If FD is conflicted, attach Conflict of Interest Form ** Interpreter Required? No If Yes, Language: Location/ETA of Defendant(s): The witness is Other Remarks: located out of state. Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 EFTA01250910